ML21225A715

Transcript for TH28

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Issue date:	03/11/2021
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

33rd Regulatory Information Conference Technical Session - TH28 Docket Number: (n/a)

Location: teleconference Date: Thursday, March 11, 2021 Work Order No.: NRC-1420 Pages 1-50 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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33RD REGULATORY INFORMATION CONFERENCE (RIC)

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TECHNICAL SESSION - TH28 I&C . . . ANALOG NEED NOT APPLY!

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THURSDAY, MARCH 11, 2021

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The RIC session convened via Video Teleconference, at 1:30 p.m. EST, Eric Benner, Director, Division of Engineering and External Hazards, presiding.

PRESENT:

ERIC BENNER, Director, Division of Engineering and External Hazards, NRR/NRC SCOT GREENLEE, Senior Vice President, Engineering and Technical Services, Exelon Generation BRUCE HALLBERT, Director, Technical Integration Office, Light Water Reactor Sustainability Program, Idaho National Laboratory NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 HASH HASHEMIAN, President and CEO, Analysis and Measurement Services (AMS) Corporation GREGORY DE LA GRANGE, I&C Safety Engineer, Institute for Radiological Protection and Nuclear Safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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4 P R O C E E D I N G S 1:31 p.m.

MR. BENNER: Okay. Good morning, good afternoon and good evening, and welcome to the closing session of RIC 2021, I&C, Analog Need Not Apply! Nuclear utilities are leaving analog in the past and pursuing digital technologies to modernize the instrumentation and controls of the existing fleet of reactors.

In parallel, a seamless digital environment is envisioned for plant operations, including the integration of plant information and processes to enable a reduced and more efficient workforce. This is crucial as plants embark into operations well beyond 60 years.

I'm Eric Benner, the NRC's Director of the Division of Engineering and External Hazards, and I'll be hosting today's discussion with national and international experts. We'll discuss their vision of what a digitally modernized nuclear plant will look like, and efforts to leave behind the analog mindset of technologies, operations, and regulatory approval.

Joining me are Scot Greenlee, Senior VP, Engineering and Technical Support at Exelon Nuclear, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 the largest nuclear fleet in the U.S.; Bruce Hallbert, Director, Idaho National Lab, and head of the Light Water Reactor Sustainability Project; Dr.

Hash Hashemian, President and Chief Executive Officer of Analysis and Measurement Services Corporation, or AMS; and Gregory de la Grange, an I&C Safety Engineer for the Institute of Radiological Protection and Nuclear Safety, the regulatory body in France, and many of the French reactors have upgraded to digital.

Each will provide some opening remarks before we dive into the discussion. I note that Scot and Bruce gave some teasers in this morning's session on current fleet 2050 operations oversight and workforce, which I think really set the stage for this afternoon's discussion. So with that, I'll turn it over to Scot.

MR. GREENLEE: Okay. Thank you, Eric, and hello, everybody. I hope some of you probably saw the morning session, and I did tee up that we were going to talk about digital this afternoon. And I didn't give too much away in the morning session, but I'll just start off with just saying, you know, we have been on a digital journey with NRC for many years. And I'm just going to say, from what I see, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 we have pretty much arrived at our destination. And I'll break this up into two parts.

You know, when we first started down this road, the premise was that licensees should be able to do digital upgrades without NRC approval on most safety systems except for the key systems like reactor protection systems and engineered safety features, actuation systems. And we do now have this flexibility under NEI 9607 Appendix D, which was approved back in early 2020. So that was a major milestone for us.

We did have similar flexibility under NRC Regulatory Information Summary (RIS) 2002-22, Supplement 1, which was approved back in mid-2018.

But the industry was concerned that, you know, the RIS might be open to interpretation by inspectors, and we believe that has been completely fixed with Appendix D. So, good day for us.

The second phase of our journey was to get agreement with -- on staff review guidance for reactor protection systems and engineered safety features, actuation systems. Now, this is also complete but not thoroughly tested yet. That's why I said we're almost there. Entergy has submitted a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 license amendment request for a digital upgrade, which is still in staff review, but appears to be going well. The big test is going to be at our Limerick Generating Station. Exelon is going to submit a license amendment request and right now it's targeted August 2022.

And we're going to upgrade all of the reactor protection and all of our engineered safety feature systems. This is a DOE partner project and the whole intent of this project -- and this was at the request of NRC -- Ho Nieh made this request quite a while back, but what we want to do is demonstrate NRC efficiency in such a major upgrade. And this will pretty much be -- well, it will be the biggest upgrade on a U.S. reactor plant. Obviously, you know, if you look at the AP1000s, you know, similar technology, but to upgrade an existing nuclear plant is a big deal.

And the good news is the results of this project will be made public and that way, the entire industry can benefit from what we learn out of this project. And from what I'm seeing, we are all going to need this capability in the future.

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8 started looking at each one of our systems and we started mapping out the failure rates. In some of our analog systems, the failure rate is becoming exponential and will not be sustainable. So now we're going to -- we're really going to need this capability going forward, and we're going to get it to the point where we think it'll be cost effective to do these sort of upgrades.

Now of course, there are other very important reasons for digital flexibility. We had a lot of analog systems that are becoming obsolete and if done right, we can, you know, deal with the obsolescence. And the reason why I say if done right is, you know, what you really have to do when you start a safety system upgrade is understand that --

or agree with the manufacturer they're going to continue to support it or agree that, you know, you really don't care and you'll just -- you know, you'll do another upgrade at some point for a non-expensive type upgrade.

Of course, digital systems are incredibly more reliable and much easier to maintain than the old analog systems. And what I would encourage all of you to do is to read a document that's publicly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 available. It's called, NEI 20-04, and this document shows the nuclear industry performance year over year. And if you just look at the SCRAM performance, it's remarkable, and most of that has to do with the digital systems that we upgraded and installed to control our feedwater systems, our turbines, and our generators. It's just -- it's amazing. And the more we can use digital, the more reliable we're going to be.

I'll give you an example of a digital upgrade we just finished at Byron and Braidwood Stations, what we call a 7300 upgrade, which is really digitizing all the remaining secondary systems we hadn't upgraded yet. And we eliminated about 80 percent of the hardware, and that's just remarkable, the reduction in the hardware. And we're expecting the same on our Limerick safety systems, because the ultimate goal in the future is to reduce our costs to operate and maintain our systems and to keep our industry viable.

And at Limerick, the goal that we set when we started this project was eliminate all of the maintenance on the systems unless the system tells you need to go do maintenance; eliminate all the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 surveillance testing; you only would do a calibration when the system says to do a calibration, so the reduction in cost to maintain the systems, it's going to be phenomenal.

One other thing I just want to put a plug in for is, you know, we've been working as an industry post-Fukushima to kind of standardize how we do modifications in the industry. And we do have a standard modification process at this point. And what the next phase is we have EPRI has developed a digital engineering guide and process guides to go with it. And the industry, our industry in the U.S.

is supposed to adopt those guidelines by the end of August of this year. And I'm just going to say I think EPRI did a great job of delivering the right guidance and delivering the training to help the industry take this process live.

And we've also got another set of guidelines. We call it the Hazard and Consequence Analysis for Digital Systems, better known as HAZCADS, and this is cutting-edge analysis methodology. It blends the PRA, the probabilistic risk assessment with what we call the Systems Theoretic Process Analysis. Only engineers could NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 have come up with this. And STPA is a proven technique widely adopted by aerospace, pharmaceutical, autonomous car companies, petrochemicals. And if you use these products, they're very, very good, and they'll ultimately make sure our digital upgrades are sound.

So with that, I'm just going to say that digital is a big deal. It's a new day for us. And I will turn it back over to Eric.

MR. BENNER: Thank you, Scot. Bruce, would you like to go next?

MR. HALLBERT: I'd be happy to. Thank you very much for the opportunity and good afternoon.

I'm Bruce Hallbert. I'm the National Technical Director for the DOE-sponsored Program, Light Water Reactor Sustainability. This is DOE's program for light water reactor research, development, and demonstration. And the goal of the program is to enhance the safe, efficient, and economic performance of our nation's fleet so that we can extend our operating lifetimes.

Our goals within the program focusing on how to accomplish that emphasize two things; one is enhancing economic competitiveness of the existing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 fleet. So we're looking ways to help plants reduce operating costs, to be toe-to-toe competitive with other power generation assets in the electrical sector, as well as the means to diversify revenue by going beyond electricity to producing other products like hydrogen, which some of you may have heard about.

The other thrust of the program focuses on ensuring the performance of structure, systems, and components in the long-term. That focuses on materials research, ensuring the performance of key system structures and components in the in-service environments like reactor metals, concrete, cables, and things of that nature, and also addressing technology obsolescence which you just heard Scot talk a great deal about. We know that over time, these technologies which had performed remarkably reliably for long periods have to be replaced. So we're looking at how to do that.

We're conducting a research program through the Light Water Reactor Sustainability Program, and I'm going to emphasize the research we're doing with digital technologies. That's all being done largely in an area of our program called plant modernization. The goal of plant modernization NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 is to conduct research, produce technologies and results that can help utilities, owner-operators, and vendors and suppliers deploy advanced digital technologies and significantly reduce the technical, financial, and regulatory risks of modernization.

The research activities fall into two areas. One is, as you could imagine, developing and demonstrating new digital instrumentation control technologies, which offer the opportunity to make significant improvements in operation efficiencies through broad deployment and also achieve significant cost reductions.

The other is also developing new operational concepts, so it's not just a matter of replacing analog with digital if the digital technology just performs things in a like-to-like manner to the analog technology it replaces. Rather, the utilities that we're working with are looking for ways to achieve broad business improvements and developing new operational concepts for their plants going forward in the future. The more digitally-enabled technology puts new technologies and automation in the hands of the workers in our skilled workforce.

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14 So we're trying to transform from an approach upon our operation that is today very labor-centric, very manually labor-centric to one that is more technology-centric and enables workers in our workforce to be able to monitor and perform the work with the plant using automated tools and technologies.

So the types of things that we're doing through the program are developing new technologies to enable modernization, conducting studies with and at nuclear power plants just like the Limerick project that Scot talked about, where we're going to do research together that not only results in change but demonstrates to the entire industry how to move forward. How do you take a challenging concept that maybe is too big to bite off from the very start, break it down into its constituent pieces, engage those relevant organizations like NRC, vendors, suppliers, and the owner/operators to be able to move forward in a manner that demonstrates progress and results?

So we'll also be producing end-state requirement studies, which we've done in support of Exelon and other utilities, and cost benefit studies.

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15 I know that many plants ask the questions when they hear about these projects, well, sure you can do it, but what's it cost, and is there a cost-benefit to doing it? So along with the research and the demonstration aspects of the work that we do, we also conduct a lot of cost-benefit studies.

Now, I'll also add that we're not the ones doing the cost benefit studies. We contract with those organizations from industry who are expert in doing cost benefit studies and are already doing those with utilities to begin with. So they know the business model of utilities. They look at the projects. They look at the technologies. They looked at the proposed approaches, and then they will provide an independent assessment of the cost-benefit of the proposed research.

Related to how we do this work. We do this work by partnering, by collaborating and conducting cost-shared research and private-public partnerships, meaning we work with utilities, we work with vendors to conduct these activities. Scot mentioned we're involved in a very large project with them on the modernization of the Limerick safety systems.

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16 We're also doing work with a number of other utilities as well. We've been working with Excel, looking at how to develop technologies to enable broad business improvements and reduce operating costs to a price point that enables them to be toe-to-toe competitive with power generation assets in their markets.

We've also been working for a long time with Palo Verde in the Southwest. It's my pleasure to say that we've got a very, very strong partnership with them on control re-modernization projects where rather than just doing piecemeal replacements of aging systems, we've developed sort of a long-term strategy through steps and stages of modernization that enables them to move forward and engage directly with their vendors to show them, this is what we want.

DOE has also made several awards to organizations who are looking to deploy advanced online monitoring technologies that can be used to replace surveillances, inspections, tests, and many things that are done manually today and provide real-time information 24/7 about plant performance, thermal performance of the plant in many of those systems. USA received an award and we're working NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 with five utilities through the USA organization to demonstrate and deploy a variety of different techniques and technologies.

We are also working with PSE&G at the Salem Hope Creek and also Rolls Royce to look into advanced online monitoring technologies, as well.

So I'm happy to say that the LWRS Program is conducting a lot of activities in real-time at and with commercial nuclear power plant owner/operators as well as the vendor-supplier community, because we want to enable that community to take the technologies, move forward and deploy them across the fleet. And I'll just stop there now because I know my time is running short and just say I'm very happy to be a part of these activities working with organizations from the industry, with the NRC and look forward to any questions you may have.

MR. BENNER: Thanks, Bruce. I think you raised a good point. This is not just about replacing hardware. It's about, you know, rethinking your operations (audio interference) contribute to some of the dialog we'll have later. So with that, I'll turn it over to Hash.

MR. HASHEMIAN: Well, thank you. Can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 everybody hear me good? Yes?

MR. BENNER: Yes.

MR. HASHEMIAN: Well, thank you, because, Eric, you were breaking up a little bit. I don't know if it was just my computer or everybody else so. Well, thank you, Eric, for inviting me and thank you to everybody for listening to me.

I just want to start by drawing a picture of the reactor of the future. I know this panel is about digital I&C for process control and monitoring of plant safety. My talk is on application of digital technologies for condition monitoring of equipment and processes in nuclear power plants.

So the reactors of the future obviously are going to have an online condition monitoring system that will tell you when and where you need to go to touch something. The good news, ladies and gentlemen, is that the reactors of the future are here today. In fact, the existing fleet have sensors that measure process parameters, but these same sensors, if you can take the data faster than normal, can tell you a lot about the health of the sensors themselves and the health of the process. For example, today plant process computers take the data NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 from, say, pressure transmitters (unintelligible) once every second or once every 10 seconds. Now if you take that data once every millisecond, you can do a lot of things with it.

Today -- and I'll give you an example --

today we calibrate all the safety-related pressure level and flow transmitters in nuclear power plants, and we've been doing this for over 40 years, and we have a ton a data on calibration of pressure level and flow transmitters. And if you look at that data, it will tell you that 90 percent of the pressure transmitters do not lose their calibration over a single fuel cycle. But we don't know a way to find out where those 10 percent that are need a calibration, plus when we calibrate those 90 percent of the transmitters that did not need a calibration, you screw up at least 5 percent of them during the calibration.

So today we take the data and plot it and look at it on a piece of paper to see if there is a drift on the output of the pressure transmitter while the plant is operating or is it drifting up or drifting down and if so, we calibrate it. If it's going straight, we leave it alone. So we do that by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 just looking at plots, but you can use AI very easily

-- we haven't done it yet -- and automate that where the computer sits there for the whole cycle and will tell you at the end of the cycle which transmitter you have to calibrate and which ones you can leave alone.

Now we've done this at the Sizewell nuclear power plant for the last 16 years, and the estimate of the savings from elimination of these unnecessary calibrations by Sizewell is $5 million.

I know that's a big number. We're not going to realize that kind of number in the United States.

Bruce asked me yesterday to give him a cost estimate on what it costs to do this and what it saves the plant. And I just responded to him that it's only fully been done at the Sizewell plant, and they are saving $5 million a cycle. It cost less than a million dollars to install that system in there.

For the U.S. plants, it won't be more --

won't be as much. You can ask me a question. I'll give you what I think a U.S. plant is going to save by putting online monitoring on a nuclear power plant.

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21 can you look at the drift and thereby determine whether or not you need a calibration, but you can also do a lot of other diagnostics. For example, pressures of transmitters having sensing line or impulse line that can connect air or have junk in it and block. And if they block, it's going to slow the transmitter down. If you take the data fast, not only can you tell about the calibration, but you can also verify whether or not there is any problem in the pressure-sensing system such as the pressure-sensing line.

Now I was also asked to talk about SMRs, instrumentation and control systems for SMRs, and advanced reactors and microreactors. The answer to that is that is that sensors do not exist with these plants. There is a lot being done to develop them but today if you have an SMR, the existing sensors are not going to be able to do the job very well.

And unfortunately, we don't have qualification standards to qualify any new sensors that are there, so the standards have to be written. So that's a big gap that has to be fixed.

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22 already there can tell you a lot about what you need to know, about the sensors themselves, the measuring system, and the process. If you dont have enough sensors, as you all know, you can install wireless sensors, and there are these wireless sensors that we call them lick and stick wireless sensors. And these wireless sensors have been implemented in nuclear power plants, and the cybersecurity and EMC interference issues that people are worried about really are not insurmountable. So wireless sensors can really amplify the ability to do condition monitoring in nuclear power plants.

So thats everything I wanted to tell you, but I have two examples of using existing sensors in existing nuclear power plants to do amazing diagnostics, but Im going to wait for you to ask me to describe those. So thats the end of my presentation. Thank you very much.

MR. BENNER: Thank you, Hash. I think it is interesting that this isnt just a hypothetical, that youve demonstrated (audio interference) make the investment. So I think that would probably (audio interference) for people to hear. So with that, I'll turn it over to Gregory.

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23 MR. de la GRANGE: Good morning, good evening, good afternoon. Let me take a moment to say I appreciate the opportunity to be here and speak today. I'd like to thank the NRC and especially Eric for the invitation. I hope I will be able to provide some international perspectives on the discussions.

In my opening remarks, we talk about two points.

For the first one, I would like to go back to the approach used to design a situated digital I&C system. Digital systems offer increase in computation and interconnection capabilities. They enable advanced functions to be carried out, such as calculation of the critical heat flux ratio and to detect (unintelligible) in real-time and provide operators with rich flexible interfaces. However, (unintelligible) affected by faults that make their logic system inadequate in certain cases which introduces sources of failure, other than random power failures and raises questions about the informal concept of increased complexity of I&C.

Appropriate design principals shall, therefore, be applied so that this logic as fault-free and can be assessed by independent bodies such as IRSN in France. This is why manufacturers, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 utilities, and technical bodies have recognized the need to define specific approach for the design of the digital I&C systems of nuclear (unintelligible) to be able to demonstrate the correctness of the logic.

Independent verification and validation according to a technical justified strategy constitute a complementary progression. This approach has evolved over to time to take into technology calibrations, such as network communications, as well as scientific and technical progress, such as formal verification based on mathematical approach. This is fully consistent with the international consensus expressed in the IAEA texts and the IEC nuclear standards.

(Unintelligible) to do it on the other industrial sectors where I&C performs important safety functions, such as analytics, space, and rate.

The relevance on this approach is confirmed by the experience from the digital safety systems over 30 years. For example, logistical processing systems in French power plants has not experienced unsafe failures (unintelligible). I would use this remark to jump from my second point NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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25 which is a brief presentation of the nuclear in France. We have 56 pressurized water reactors operating in France each amongst one of (unintelligible) generations. The first is called the CPY. There are 32 reactors designed in the 60's throughout the USPWR. They are (unintelligible).

The second generation is called P4. There are 20 reactors designed in the 70's. The I&C is based on digital technology, but the main control room, the mechanical control room is quite similar to the first generation CPY. The last is called N4. There are four reactors designed in the 80's. Here the whole I&C is based on digital technology and also the main control room is mainly computerized. So we can say that the first generation CPY can easily be used as (unintelligible) with the U.S. reactors regarding the modernizations mainly because they have a similar design at the start.

In France, we have specificity with which has a major impact on modernization strategies. This is we have only one licensee to operate all nuclear power plants in France, which is EDF. So we can say that decisions may concern a lot of reactors. From an IRSN perspective, we have generally assistance.

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26 And before I finish, let me say a few words about the French regulatory. We use mainly French basic safety rules which are higher than requirements (unintelligible) the software needed for the safety rating systems. And we also use the IEC nuclear standards.

So that's all for me. Thank you.

MR. BENNER: So, thank you, Gregory. I think it's good to get the international perspective in this discussion.

So Sam, can you bring up the first polling question, please? And for those in the audience, the polling question will be located under the polling question tab in the upper right corner, so please respond to the poll and please submit your other questions using the questions tab as I see some of you have already done.

So the first polling question is, what's the biggest challenge to complete digital modernization of the operating control room? And it looks like we have a tie of cost and business risk and having an end-vision and implementation plan.

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27 not jump to the top of the list. I will ask the panelists if they have any reactions to these poll questions.

MR. HALLBERT: So Eric, I can -- oh, looks like --

MR. BENNER: Oh, I jinxed myself.

MR. HALLBERT: Yes. You spoke too soon.

MR. BENNER: That's okay. I -- it -- I mean I get it. Until we all demonstrate that that's a component, but I'll let the other panelists react overall. There we go. Now the people are coming out.

MR. HALLBERT: Can you hear me okay, Eric?

MR. BENNER: Yes, Bruce. Thank you.

MR. HALLBERT: Okay. So we've had some

-- we've had workshops, sponsored workshops through the LWRS Program. And we've asked similar types of polling questions and similar results. You know, utilities are interested in moving forward with plant modernization, digital upgrades, but they -- what they want to do is part of a larger, longer term asset management strategy. So they don't want to just invest in islands of automation and then have a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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28 collection of systems around the control room that don't work together and aren't harmonized and optimized.

The other thing is, of course, go along with that, the question is, how do they make the justification, the cost benefit justification for the investment? And, of course, people always ask about who's going to be the first to do this and will we be able to address a regulatory uncertainty issue. So we've heard various similar types of things from the stakeholders that we work with from industry.

MR. GREENLEE: Yes. I guess I would say that the number one thing is the uncertainty on safety systems. There's, you know, very little uncertainty on the non-safety systems. As I mentioned for Byron and Braidwood, you know, we did this huge digital upgrade on the secondary side and the cost benefit was amazing. So the business case was there and, you know, removing the uncertainty from the safety case is really what the Limerick project is all about.

And that's going to come with a guide that has been developed by one of our industry partners on how do you make the business case. And so hopefully, when we get through this Limerick project, it'll be 2024-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 2025 outages where we install these upgrades.

Hopefully, when we get through that, we can provide the industry with, you know, lessons learned on how to make this cost beneficial.

MR. BENNER: Okay. Thank you. So we have our first question from the audience, and I think it's mainly directed at Scot. It says, "You mentioned that analog systems' failure rates are going up exponentially. Did you mean equipment hardware failures probably due to age, or there are also human reliability issues related to these systems?" So --

MR. GREENLEE: I would say no on the human reliability and yes on the hardware. It's primarily the circuit cards. Some of these systems have a huge number of circuit cards, and when you start looking at, you know, how often the I&C techs have to go out there and, you know, replace a circuit card, it's a little scary.

MR. BENNER: Okay. Thanks for that feedback, Scot. So a second question, and I'll direct this to all members of the panel, does going digital also include the use of wi-fi for connecting I&C components?

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30 MR. GREENLEE: And I am going to say yes.

It's interesting. We've been on a journey at our different sites on wi-fi versus putting in a distributed antenna system. We have elected to go ahead, and we'll start next year, putting in distributed antenna systems, but the -- because the big thing with the wi-fi is we, at least at Exelon, we can't connect it to the business network. There's too much business risk, so you have to have basically a separate wi-fi system, which some of our plants do.

But the distributed antenna system is an amazing piece of hardware, and it has penetration capabilities that wi-fi doesn't have so you can get greater coverage with distributed antenna systems.

Our vision at Exelon is put in the distributed antenna systems and put in -- like Hash was saying, we want to put sensors on everything so that condition-based maintenance becomes the norm versus our time-based maintenance.

The other thing I would just mention, too, is we're developing specifications for when, like, for example, we send a motor out for refurb, that motor ought to come back with embedded sensors that we can just pick up on wi-fi or a distributed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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31 antenna system to get more information on the health of that motor.

MR. BENNER: Thank you, Scot. And I think that point, that reinforces something Bruce said, that it's about rethinking how you're going to operate the plant; it's not just about replacing a piece of hardware.

So, do any of the other panelists want to give views on that question?

MR. HALLBERT: So, I'll mention that in the projects that I referenced in my presentation dealing with online monitoring where we're looking at providing real-time monitoring of components, doing real-time monitoring for things like fire watch, that we are working with wi-fi technology and also adding more sensors than we've ever had before monitor equipment and systems. So there's a lot more that can be done, a lot more data that can be provided in real-time.

Along with that, we're also developing AI and machine learning algorithms to gather intelligence from that distributed sensors system throughout the plant to be able to provide a grounds-up better picture of what's happening in the plant.

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32 That could also be used for other uses in the future, like digital twins.

MR. GREENLEE: And Bruce just mentioned fire protection. I think that's a good illustration of technology. We've actually partnered with a company to build fire carts for us, so these fire carts are able to do all of the fire watch duties whenever we get into a fire watch situation. And we also have them build carts just actually pick up wireless data. So if we don't have a wireless network in place in some part of the plant, we can take a special cart out into the plant and it can pick up the wireless data for us. That's kind of an interim strategy while we're getting DAS installed.

MR. BENNER: Okay. Awesome, guys. The next question is directed mainly at Hash. And it says: What are some other examples of how digital technology has improved data acquisition in nuclear power plant I&C testing?

MR. HASHEMIAN: Well, thank you. So since this question is specific to RTDs, I'm going to talk about what we call RTD cross-calibration. So, when the plant is at isothermal conditions, all the RTDs in a PWR plant are basically seeing the same the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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33 temperatures. So you deploy a data acquisition system and measured what they read to see if one doesn't agree with the rest of them, because they're all supposed to be reading the same thing. That's called RTD cross-calibration. It's a very simple process.

Now, you can do that using data from the plant computer if all the spares are also in the plant computer. If the spares are not in the plant computer, that may be a problem.

A good thing about the RTD cross-calibration method is this. If you take the data during plant startup and an RTD, for example, is not good, you don't have to cool back down and replace it. You can use the data to actually in situ to re-calibrate that RTD. We do that all the time. It's not abstract. So, we basically use the reading of the other ones to provide calibration constant for the one that is what we call outliers.

And I have two other examples to describe to this question, but I'm going to wait and see if there is time, and then I'll come back if you want me to, Eric.

MR. BENNER: Okay. Wonderful, Hash.

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34 The next question is mainly directed at me, so I figure I can't hide. It says, the NRC has made strides over the past several years in improving the regulatory structure for digital systems. However, the NRC still relies on a Commission paper from 1993 for its policy on common cause failure for digital systems. Given the advances in digital design and technology since 1993, what additional changes can and should the NRC consider to remove the remaining barriers to safe and effective use of digital technology?

And I'll say that we did issue a paper to the Commission two years ago that looked at the 1993 policy that's referenced. And at that time we felt that the policy, even though it was old, was not impeding any of the initiatives we were working at that time. But I did tell stakeholders, if they thought that the policy was impeding where we would like to go, to raise that. And I believe we may have a conversation surrounding that in the near future.

I will say the staff is open to revisiting the policy with the Commission, but we don't want to do that unless it's a clear impediment, because it just -- that takes energy and it takes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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35 time. And then the Commission is on its own schedule. But we are very much open to having those conversations.

So, with that, Sam, can you pull up the second polling question?

MR. GREENLEE: Hey, Eric?

MR. BENNER: Yes. Okay. I'll let -- I should let other panelists weigh in before I move on.

But, Sam, can you put up the polling question in the meantime and people can start weighing in on that?

MR. GREENLEE: I probably should have mentioned in my discussion, but we are, as an industry, developing a document that ultimately we will submit to NRC for review, through NEI, on common cause failure. So we are putting together something that we will ultimately get to you, Eric.

MR. BENNER: Okay. Wonderful. Thank you. Because I will say I think what has made the improvements a success so far is there has been good communication and cooperation between the NRC and all of our stakeholders to develop guidance documents that have utility. So, I think we've demonstrated that in the 50.59 realm so far, and I'm hoping we will be demonstrating that in the licensing realm.

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36 So, just give a minute here for the polling questions. And this doesn't surprise me.

This question, obviously, it's the answer -- the question is: at my facility, digital upgrades will primarily be..., and then it lists a number of different options. So I did suspect that there would be more variability in this answer because, obviously, each licensee is going to look at the challenges they're facing.

I will say I'm a little surprised that integrated systems has jumped up, but I will just let any of the panelists give any reactions they'd like to give to the polling results as they come in.

MR. HALLBERT: So, Eric, again, some of these results are reminiscent of the questions that we had asked our stakeholders as we were deliberating on what research and control room modernization to prioritize and how to go about it. And it was based upon discussions and observations of some of the early work that we were involved in with the industry where we were supporting some single-system replacements.

And as people realized, it's possible to end up with a collection of individual systems in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 control room that are all not tightly coupled together in terms of, you know, functionality or even user interfaces. So an operator goes from one system to the other and, you know, the way of using them and the experience of using them is slightly different.

So, some of the input we were receiving from those that were planning on moving forward, at least, was that they knew to have systems that were not only integrated physically, digitally, but also functionally from the standpoint of human system interface requirements to process for validating the technologies and systems, and like that. So I think some of these polling question results reflect very practical concerns that some of the first movers have with regard to deploying digital technologies in their plants.

MR. BENNER: Thank you, Bruce. Do any of the other panelists want to provide a reaction?

MR. de la GRANGE: I can prove an overview of what has begun in France on the reactors.

I can separate from generation because renovation depends on the generation of the reactors. For the CPY, which is the first generation, the main mode of modernization is (unintelligible) about the sonic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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38 instrument testing system, which is a safety-rated system. The previous was internal electronics. It has been replaced by a digital system with the same interfaces. They did some functionalities to improve the reactor electronic (unintelligible). They had to adjust these added functionalities as it first started, but now the feedback is very good.

All the second generations have been from retrofits. They did a retrofit of the protection system. The previous system was designed in the '70s and '80s, so based on the (unintelligible) from this period. And now this is a modern technology (unintelligible) needs, engineer uses networks where dramatically the hardware conditions. New product systems keep the same interfaces, still very good feedback on that.

For the last generation, there is no modernization of these reactors.

MR. BENNER: Thank you, Gregory. So we have another audience question, and I think any of the panelists may be able to weigh in on this. The question is: how are plants dealing with the life cycle management of their digital replacements with off-the-shelf IT equipment having a three- to seven-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 year life-span and vendors iterating their equipment every six month to a year? This is in consideration that some analog systems have been installed for 30-plus years.

MR. GREENLEE: I'll take a quick shot at that. As I mentioned in my opening remarks on obsolescence, you've got to start with the end in mind when you upgrade a digital system. Sometimes you might not care because you can just plug and play if they're, you know, inexpensive and easy-to-replace parts. But I will tell you, when the case at Byron in Braidwood with the 7300 upgrades, we started with the agreement with Westinghouse that they were going to continue to support the plant for the life of the plant. So, you know, that's the sort of thinking you need to go into major digital upgrades.

MR. BENNER: Okay. I'll go to the next audience question. Will the plant modernization projects leverage the DOE's digital twins research and development?

MR. HALLBERT: It sounds like that might be directed to me based upon the presentation. And the answer is yes. The technologies that we're developing, especially in the online monitoring, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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40 research projects with USA and the PSEG/Rolls-Royce are developing with ASIS for a full suite of sensors to support broad use of data analytics, and eventually to build up and support the digital twin types of activities. And some of our research staff are connected in with those digital twin R&D projects. So I'll just say, yes, and that is the goal.

MR. BENNER: Okay. Thanks, Bruce.

MR. GREENLEE: I would say, at least at Exelon, we really don't have a lot of what I would call digital twin work going on. We did take a group of us over to Paris to benchmark EDF and look at their digital twins. And I guess at this point I would say we are not really exploring that, but, you know, there does appear to be value there. It's just we haven't gotten into the actual work at this point.

MR. BENNER: Okay. Thank you Scot. The next audience question is, does industry view their current cybersecurity requirements as an impediment to the further implementation of wireless communication for safety systems?

MR. GREENLEE: No.

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41 it's not. And this question keeps coming up. It's not. We actually have wireless system working in the containment of operating nuclear power plants, and it's been there for a while and nothing has happened.

So, don't be scared of cyber and interference. Now, there is going to -- it's not zero, but it's not a problem that you cannot solve. And every time you use something new that does a lot of good things for you, there's a few things that you're going to have to do to make the problems go away. My answer is the same as Scot: no.

MR. GREENLEE: The only thing I would preface, and I've said this before, is, you know, at Exelon, we don't tie our monitoring networks into our business network, because there is hacking capability going through sensors that presents a business threat to us. But it's not a nuclear cyber threat by any means.

MR. HALLBERT: I would also echo what the other panelists have said, in that, you know, cybersecurity is another one of those non-negotiables. We have to have it for our systems to be secure and safe. Those just go hand-in-hand. So, you know, the question is how do you do this. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 I'm happy that, you know, DOE has a very robust cybersecurity program. NRC and industry also have very robust cybersecurity programs and initiatives.

And so, collectively, this all works to the advantage of our critical infrastructure, which is just needed to have confidence in our ability to operate and operate safely. So, it's not an impediment. It's something that we absolutely have to do.

MR. BENNER: Thank you, gents. So, the next question is directed at Gregory, but you all can provide feedback if you'd like. So, the question is:

how do you keep your people up-to-date with the latest technology? So, I guess it's, you know, the technology that's adopted by your licensees, how does the regulator keep abreast of that?

MR. de la GRANGE: Well, the safety rating system, (unintelligible) they don't use the very latest technology so we still -- to keep up to date with the technology, we have a lot of research and development with a research organization. And we keep -- we have a project with them. It's a way to be up to date with the technologies but, for example, we don't use in the safety rating system the wireless technology. So this is -- we want to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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43 promote some formal methods, and we use this kind of technology to have some route on the software. This is where the researcher helps us in developing these kind of formal methods.

MR. BENNER: Thank you, Gregory. Does anyone else want to weigh in before I go to the next question?

(No response.)

MR. BENNER: So the next question from the audience is: what are the hurdles preventing the industry from fully adopting condition-based maintenance?

MR. GREENLEE: I will certainly weigh in on that one. The biggest key for us in Exelon is getting more ability to take in wireless sensor data and get it into, you know, a computer somewhere. And like I said earlier, our plan there is to install distributed antenna systems, because they are really the most advanced systems that you can put in. And then you can, like Hash said earlier, they can stick sensors, like I said earlier, you can put into your specs. When you get equipment refurbished, you know, you ought to come back with the latest and greatest technology for monitoring that equipment. But NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 there's no really big barrier, at least for us, it's just building that.

MR. HASHEMIAN: Can I add to that, Eric?

MR. BENNER: Certainly.

MR. HASHEMIAN: All right. Thank you.

In the case of calibration monitoring, so, the NRC is looking at the topical report that DOE funded that we did, and that's going very well. Put a little plug for NRC and they have been very good at looking at it, asking great questions. We are looking for the NRC to do a safety evaluation. And once that's up, then the online monitoring can be used to get rid of the unnecessary calibration.

So, people say the impediment has been the regulations but, you know, this has not been our experience when the experience was accumulated. A topical report was submitted, and we are thinking that, by the end of this year, the industry will be able to use online monitoring to get rid of calibration of 90 percent of pressure level and flow transmitters.

Now, other things, such as wireless, as Scot said, there is internal concerns about the use of wireless. But, as Scot said, you can separate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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45 between the business system and the other systems and take advantage of it. Thank you.

MR. GREENLEE: And, Hash, thank you very much for that submittal to the NRC. I'm looking forward to using it.

MR. HASHEMIAN: Well, you need to thank Eric for -- he's the top guy on there and his people have been really awesome to work with. And there are still too many questions, but that's good.

MR. BENNER: Yeah. And thanks all around, because we did -- I remember the first meeting I had with Hash on this topical. And it has been a good collaborative effort. We ask a lot of questions but, you know, Hash has had good answers, so I definitely appreciate the good dialogue.

Sam, I'm going to ask you to pull up the next polling question. And, again, there's a tab up in the upper right for people. This is to make sure people are still paying attention. Wow, not applicable. I'm hoping that's just one answer.

Okay. Yes. So, that's a challenge. I'm going to step out and say that, with the tools we have out there, realize that even under 50.59 there are a lot of things you can do to do digital upgrades NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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46 in your plant. So I'm going to use this as a public service announcement to think long and hard, because I think, you know, you're hearing today some of the benefits of upgrading to digitals. So, I get it takes time to plan that, but, you know, I would ask that you consider it. And if you have any questions, I think you can talk to your industry peers or certainly you can come talk to myself or any of my staff as to the tools that are available.

MR. HALLBERT: Eric, if I add here? You know, in my experience, when Ho Nieh and Ray first approached us about sponsoring a safety-related digital upgrade project, which now, you know, we're talking with Exelon, who's leading that for the industry. I can tell you that we reached out to a number of the organizations that we have worked with, and everybody has the same needs. You know, the business case that Scot described for the high cost of aging and obsolescence is going to hit the industry, you know, pretty broadly.

But still, you know, many organizations were interested in participating but were not interested in being first. You know, you could almost say, tongue in cheek, that this is a race to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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47 be second. And so for that reason, I mean, really, I appreciate Exelon's leadership in this area and the partnership that we've built with them, because it is a big step for somebody to move forward in the safety-related digital I&C area.

In other areas, digital I&C non-safety related has been -- things have been working pretty well, and it has more to do with, you know, what's your long-term vision and strategy for your plant as opposed to what are the technical and regulatory risks. So, that's been some of our experience based upon a number of discussions and interactions that we've had with industry organizations about long-term planning. It's not atypical that people are a little bit unsure about a safety-related upgrade. And I think maybe a part of this is also, you know, showing us that more information is needed for people to understand the process and how NRC has changed its approaches, too.

MR. GREENLEE: And I guess I would say, too, that, you know, I have high confidence in the 50.59 process right now. We spent a lot of time making sure that's good between NRC and the industry, and I would encourage you, if you haven't done it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 already, get some folks into the NEI Appendix D training, because my understanding is it's very good training. And maybe that'll give people a little more comfort that they can do these digital upgrades under 50.59.

MR. BENNER: Okay. Thank you, guys.

One more audience question, and it's directed at Hash. What do you envision as the future replacement of the current flow rate sensors?

MR. HASHEMIAN: Well, thank you. So measurement of flows, this should be in the next generation, the SMRs, is going to be difficult, especially measurement of low flows. So, the existing class of pressure transmitter and differential pressure transmitter, we cannot do that.

There are new ways to do it. For example, you can use a thermocouple to measure flow rate, if you have flows that are very low and you can't measure it with any other thing.

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49 those and give you the time that it takes for the signal to go from sensor one to sensor two, and then you can use the other information to calculate flow.

So, two new ways, in addition to what's out there.

Flow measurement is going to be a major problem in some of the advanced reactors. Cross-correlations and thermocouples can measure flow.

These are new. They are not used today, but research is being conducted to determine the accuracy of flow measurement in the thermocouple. So, a thermocouple can measure temperature and flow as well as level.

So, the research is coming up soon to tell you how accurately can you measure flow rates with a thermocouple. These are important for, for example, SMR that don't have a lot of room, right?

And then cross-correlation flow measurement is also important in SMRs and new generation of reactors because you can use other sensors that do other things, like a temperature sensor and a pressure sensor that's there for other purpose, you cross-correlate the signals of those, you can get flow out of it. Thank you.

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50 answer, but I'm going to ask it anyway. And it's:

can the loss of one wireless system totally disable all of your sensor readings for RPS and engineered safety systems?

MR. GREENLEE: I'm not sure there's really a tie there because the protection system and the ESFAS system won't be dependent on anything wireless. It'll be -- you know, you'll have hard wires into the PPC. You may have some outputs that go into wireless, but, you know, the way we are going to design it, there's no possibility that wireless can impact the function of those systems.

MR. BENNER: Thanks, Scot, and I had hoped that was the answer.

So, Sam, can you pull up the remaining polling question? And, again, like in the last question, I think you heard several of us talk about, you know, that we have several products out on the street now to help licensees and inspectors with digital mods made under 50.59. NRC Regulatory Issue Summary 2002-22, Supplement 1 is a revision we issued in 2018 which clarified the use of what's called the qualitative assessment. And we have had evidence that that guidance has been used. And those mods NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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51 have been inspected, and the inspectors have found no issues, so I think that is a huge success.

And, more recently, we published our endorsement of NEI 96-07, Appendix D. NEI 96-07 is the broad guidance for 50.59, and Appendix D is a digital-specific appendix. And like Scot said, there has been one industry workshop so far, and I believe a second has already been scheduled. So this is another public service announcement if you're considering making mods to get familiar with those guidance documents, because I think they will guide you through the best way to do digital mods using 50.59.

So, with that, I want to ask Sam to bring up the closing slide. And I apologize. I thought we had had a slide that had contact information. If you have any remaining questions you would like to ask, feel free to email myself at eric.benner@nrc.gov and we'll consider getting back to you with an answer.

I'd like to thank the panelists for all of their insights and the audience for all of your participation and your questions. I would also like to particularly thank Sergiu Basturescu, Bill Roggenbrodt, the other Eric, and Sam, who are our IT NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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52 techs, for smooth operation of today's session, because without any of them, this session would not have been successful.

And with that, I'd like to allow the panelists to make any closing statements.

MR. GREENLEE: I would just say it's been a pleasure being on this panel and I thought we had some good questions today. And it's a new day in digital.

MR. HASHEMIAN: I'd like to say I'd like to see the day where nobody touches any equipment until a smart, intelligent online monitoring system tells them to go look at this and not look at that.

I think that day is coming, especially with AI doing as well as it does. These things have become so cheap and so easy to do.

And by the way, one other thing I want everybody to know, this stuff is not that difficult.

You know, it used to be difficult because the storage was expensive, high data acquisition with high speed was difficult, and all of them are all proprietary.

Now there's a lot of open-sourced AI stuff you can just go get and analyze the data, bring in newer networks so that the computer can do everything.

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53 Now, some of the things that everybody does in online monitoring still you need to look at plots and things. You can get a computer to do all of that and do a lot of it, and thereby you just sit back and the computer will tell you what you need to do to maintain this plant. I think that day will come. Thank you.

MR. GREENLEE: Totally agree with you, Hash.

MR. HASHEMIAN: Thank you, Scot.

MR. HALLBERT: I would add that I think there is great progress being made and more and more enthusiasm building for digital I&C projects in the industry. It's a highly realistic approach to dealing with technology obsolescence of the installed analog technologies. And it also enables plants and the owner-operators to create business innovation and greater efficiencies, meaning lower cost and improved reliability, in operating their plants. In an industry that's already very safe, digital technology is a great way to move forward and is also necessary for future advanced reactors as well, too.

MR. de la GRANGE: I would like to thank you again, all, to be here for my first RIC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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54 participation. So, thank you. It's been very interesting discussions.

MR. BENNER: Okay. Well, I have been thrilled to be your moderator today, and I think we had a great discussion. And with that, I will end RIC 2021. See you next year.

(Whereupon, the above-entitled matter went off the record at 2:45 p.m.)

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433